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Growing Need for Food Allergen Training

by Jennifer McCreary and Marie Lefaive

Several weeks ago, a friend bought a box of cereal. Three hours later, she was in a hospital emergency room. This friend—we’ll call her Alice—has a severe nut allergy, and there were trace amounts in the cereal. To complicate matters further, Alice was pregnant.

Alice has dealt with her allergies all her life. She is a conscientious reader of ingredient labels; she calls restaurants to verify their allergen policies; she brown bags every single workplace luncheon or professional development conference. Her trip to the hospital happened because the breakfast cereal manufacturer had changed its recipe without advertising that fact on the packaging. “I have been buying that cereal for years,” said Alice. “It was on my list of foods I could trust.”

The story has a happy ending, and Alice was able to return home from the hospital later that day. But the real issue here is that this incident never should have happened in the first place.

From a legal perspective, the manufacturer is without fault. The ingredient list was changed to include the allergens. From a broader public service perspective, however, the company made a mistake; it did not update its packaging to call attention to this changed formula. “New and Improved” or “Now Made Even Better” would have been enough to prompt Alice to read the ingredient list and would have kept her out of the emergency room.

With the number of people with food allergies and the number of recalls due to undeclared allergens increasing, a company’s culture in terms of how it handles allergens has taken on a whole new importance.

According to The Peanut Allergy Answer Book, the first reference to a nut allergy occurred in 1920. Sesame came onto the scene as an allergen in 1950. Between 1999 and 2004, the number of American children suffering from life-threatening peanut allergies doubled.

In Canada, 10 products are on the priority allergen list, up from six in the past 15 years. This summer, mustard will be added, increasing the total to 11. Clearly, allergen prioritization is on the rise. There is no reason to assume that this trend will slow down. In fact, every sign points to the opposite. As part of the Food Safety Modernization Act, signed into law in January 2011, the FDA is required to develop a voluntary allergen management program. As a result, companies may soon find themselves challenged to prove the fitness of their own programs and to demonstrate continued improvement.

Many people have a difficult time believing that a trace amount of milk powder or soy flour in a product can be life threatening. They think the industry has gone overboard in dealing with allergens.

The Allergen Epidemic

Recent numbers show that the allergen issue is a sizeable concern:

According to the FDA, food allergies affect about 2% of the U.S. adult population and 5% of children.

FDA figures also report that anaphylaxis due to allergic reactions to food results in 30,000 emergency room visits, 2,000 hospitalizations, and 150 deaths each year.

Various sources estimate that 30% to 50% of recalls result from undeclared allergens.

There are no figures available on the cost of recalls to the food processing industry, but if we assume even a very conservative $100,000 per recall (this includes the cost of product, lost sales, administrative and marketing costs, and damage to brand image), the total could be staggering.

It’s important to remember that allergens are only a problem when they exist in a food product but are not listed on the label. This can happen in a number of different ways, including mislabeled packaging, undeclared allergens in raw materials, and cross-contamination during the production process.

The first line of defense is awareness training for all personnel. What is an allergen? How can it enter your product? What are the different categories of allergenic response? Why is it everybody’s responsibility to prevent undeclared allergens from entering your product? What can happen if that responsibility is overlooked? A good training program addresses each of these topics. The greatest challenge, however, is convincing learners to care enough to move the lessons from the training room to the production floor.

Many people have a difficult time believing that a trace amount of milk powder or soy flour in a product can be life threatening. They think the industry has gone overboard in dealing with allergens. To be fair, discussions of allergen prevention programs were unheard of 30 years ago. Deaths from bee stings were more common than from food allergies, Epi-Pens were unheard of, and peanut butter sandwiches were allowed in classrooms everywhere. But for whatever reason—and there are several theories out there—food allergies are on the rise.

One way to raise awareness of this fact during training is to show the numbers. A peanut speck that fits on the head of a pin—1/1000th of a peanut—can kill a child. A kiss from someone who recently ate shellfish can lead to an immediate anaphylactic reaction. Show them images. Make it memorable.

A second extremely effective technique is to find a colleague who can act as advocate. The words of a co-worker whose son nearly died due to an anaphylactic reaction will hit home with your learners. Suddenly, it’s not just a list of statistics and numbers. It’s personal.

In a demonstration that we use in our training sessions, a container sprayed with Glo Gel is passed around the table, and trainees are asked to remove a sealed envelope from the container. After everyone has performed the task, the lights in the room are turned off, and a UV light is lit. They are then asked to hold their palms facing up. The eerie blue glow from the specks of powder on everyone’s hands is a graphic demonstration of just how easy it is for cross-contamination to occur. When we point out the fact that every person in the room just had a hand in spreading the allergen, the light bulbs go on in their heads.

Let your team work through exercises at each step until they are comfortable with the process. It is a skill set that they will be able to use not only when developing their allergen prevention program, but also in many other areas of food safety.

Deep Defense: Training to the Next Level

Key to any successful allergen defense program is training those whose jobs carry a greater responsibility. The strategy here is to structure the training to the function. For example:

Purchasing. How can you be sure that your supplier program protects the company from unwanted allergens? What is the protocol for emergency situations when a supplier cannot meet your requirements?

Receiving. What are your responsibilities for ensuring that incoming raw materials match their specification sheets? What is the procedure to follow if you suspect possible contamination of a product?

Sanitation. What does peanut residue look like on a food contact surface? How long must a detergent remain on a surface to denature the protein in the allergen? How do you validate your sanitation protocols?

Processing. How is the allergen program integrated with the pre-op inspection? What is the production scheduling protocol when running allergen and non-allergen product on the same line? What traffic and people flow processes are in place to prevent cross-contamination?

Packaging. How can you confirm that the right product is linked to the right package? How do you dispose of out-of-date labels?

Employees must understand why certain policies are in place, what the procedures are for deviations, and who is responsible for ensuring that their part of the program meets requirements. For any company that is certified to a food safety standard, either local or international, knowledge of and adherence to the documentation requirements is an added layer.

The most successful training programs are those that allow users to practice the learning. Have the sanitation team practice swabbing, and show them what happens when a detergent is not applied correctly. Develop different traffic pattern scenarios, and ask your processing team to identify cross-con­tamination points. Challenge your group to identify potential allergens in incoming product spec sheets. And, as with the previous awareness training, make it personal: This is their job, these are their responsibilities, here is why it is important to do it right, and here is the place to practice.

Central Command: Training for Senior Staff and the Allergen Team

This final level of training supports the backbone of your allergen program. The allergen team’s job is to take an inclusive view of your complete operation, to determine what could go wrong, and to put procedures in place that mitigate such circumstances. If we return to our story of Alice and her box of cereal, an effective allergen program would have anticipated that the end user might fail to notice the changed formulation. The company would have addressed that risk with labeling and packaging changes, looking beyond legislative requirements to protect both their customers and their brand.

In many companies, the allergen team and the food safety team are the same. At times, the “team” can be a group of one. Whatever the make-up, a primary focus during training is risk assessment, because it is through risk assessment that potential dangers are identified, classified, prioritized, and addressed. Risk assessment is also a key requirement of most GFSI standards.

An effective approach is to build the training program around the four main steps to risk assessment:

Hazard identification: What are we worried about?

Hazard characterization: How bad is it?

Exposure assessment: How much are people likely to get?

Risk characterization: What is the severity and likelihood?

Let your team work through exercises at each step until they are comfortable with the process. It is a skill set that they will be able to use not only when developing their allergen prevention program but also in many other areas of food safety. It will be worth the investment to ensure that the training is well designed and delivered and that your team fully internalizes the lessons.

A Plan for the Future

Training is an integral part of the management program. Remember that the bulk of all allergen-related recalls occur due to human error or ignorance. A BBQ meat product is recalled because the Worcestershire sauce it contains has anchovies in its formulation. A sushi company fails an audit because the teriyaki sauce that it uses contains soy and wheat, and no allergen prevention program was in place. A processor must recall a day’s worth of production because the right product was put in the wrong bottle. All employees, from the receiver to the packager, from the sanitation crew to the CEO, must be aware of the danger of allergens and of their own roles in ensuring a robust prevention program. Your brand, your business, and your reputation require it.

Jennifer McCreary is manager of customized training and Marie Lefaive is manager of program development at Guelph Food Technology Centre. They can be reached at info@gftc.ca or online at www.gftc.ca.

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Food Quality & Safety (formerly Food Quality) is the established authority in delivering strategic and tactical approaches necessary for quality assurance, safety, and security in the food and beverage industry.